Wearing scrubs, Massachusetts Nurses Association jackets and stickers saying, "Every patient deserves a nurse," they told the Board of Registration in Nursing that administering medications should be the responsibility solely of licensed nurses who know the effects of different drugs and can assess a patient's condition before offering a dose.

The board is weighing a series of amendments to its regulations, including revisions to the section governing delegation of certain nursing activities to "unlicensed persons" — workers who are not licensed as nurses but perform complementary or assistive roles, like orderlies, aides, assistants and technicians.

Nurses association president Donna Kelly-Williams said in written testimony that the proposed regulations "could be interpreted by unscrupulous health care administrators as a gateway to allowing unlicensed people to administer medications to any patient in any setting," including in hospitals and long-term care facilities.

The Department of Public Health, however, said the changes would not expand the limited settings in which nurses are authorized to delegate medicine administration.

Hospital nurses who spoke at the hearing expressed fears they would be pressured to delegate medication administration, though the regulations specify that the decision to delegate "is made by the delegating nurse only" and employer policy or contracts cannot mandate delegation.

"Today we are under a great deal of pressure to delegate things, and that delegation pressure comes from above, from the managers, and they are under pressure for us to delegate more and more things," said Nora Watts, a nurse at Newton-Wellesley Hospital. "Don't make any mistake, there will be so many more errors if we do this because of how complicated the medications are, and you're putting me and my family and your family and the people of the commonwealth of Massachusetts at great danger if you go forward with these changes to medication administration."

William Lahey, a nurse at Worcester's Saint Vincent Hospital, said he believed the proposal was an attempt at "cutting the costs of having registered nurses."

Nurses are currently only authorized to delegate medication administration in public and private school settings, and that would not change under the new regulations, according to the Department of Public Health.

"The proposed amendments make no changes in current state law governing to whom a nurse may delegate medication administration, but rather serve the interests of patient safety by clarifying existing regulations on the delegation of nursing activities, including the administration of medication," DPH spokesman Tom Lyons said.

Rep. Denise Garlick of Needham, a nurse and chairwoman of the Joint Committee on Elder Affairs, urged the board to take care in the wording it chooses, saying the proposed regulatory language could have unintended consequences.

"The specter of unqualified and unlicensed personnel administering meds in any setting, if that is not your intent, must be unequivocally repudiated," Garlick said.

Addressing the board alongside Worcester Rep. Mary Keefe, Garlick said 71 lawmakers had signed onto her written testimony and that there was a "large cadre of legislators who want to be vigilant about this process."

Meg Doherty, a former chair of the Board of Registration in Nursing, spoke in support of the amendments, saying there are not enough nurses to meet the medication need of patients who wish to remain at home while receiving care.

"Change will continue at an exponential rate and currently untrained care aides, neighbors, anybody, are hired, directed by patients in their homes, and to me, this is an unsafe practice as opposed to creating safety parameters," she said.

The Home Care Alliance of Massachusetts also offered support for delegation in home settings, submitting written testimony that said the new regulations would build "a framework which would permit home health nurses to operate at the top of their license, retaining those responsibilities pertaining to assessment and critical decision-making."

The alliance's testimony said the changes would increase "the efficiency and availability of care at a time when the number of elderly in our population, including those who will be cared for at home, is drastically increasing."

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